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Multistate Tax alert archive

State tax legislative, judicial, and administrative developments

​The Multistate Tax alert archive includes external tax alerts issued by Deloitte Tax LLP's Multistate Tax practice during the last three years. These external alerts highlight selected developments involving state tax legislative, judicial, and administrative matters. The alerts provide a brief summary of specific multistate developments relevant to taxpayers, tax professionals, and other interested persons.

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Most recent Multistate tax alert

State income tax effect of proposed federal intercompany debt regulations

On April 4, 2016, the Internal Revenue Service (IRS) issued proposed Treasury regulations under Section 385 of the Internal Revenue Code1 (Proposed Regulations) that would, if adopted in their current form, have a wide-ranging impact on intercompany debt, including requiring certain debt instruments issued between related parties to be recharacterized as equity, and establishing minimum documentation requirements that must be satisfied for intercompany debt instruments to be respected. While the Proposed Regulations are not intended to affect debt between members of a consolidated federal return for federal tax purposes, they may have implications for state income tax purposes, especially in states that do not fully conform to the federal consolidated return regulations.

In this tax alert, we summarize and highlight the relevant provisions of the Proposed Regulations and provide some taxpayer considerations in light of the potential state income tax implications. For a more comprehensive discussion, please see the Deloitte United States Tax Alert, Proposed Regulations Addressing Treatment of Certain Interests in Corporations as Stock or Indebtedness, issued April 6, 2016.

2014 Multistate Tax alerts

Find out what you missed in 2014. Explore our archive.

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2013 Multistate Tax alerts

Key updates in 2013. Explore our archive.

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